We are a registered investment advisory firm working primarily with qualified retirement plans. We are writing in response to the Commission’s request for additional comment on the voluntary redemption fee rule.

We urge the Commission to adopt uniform standards for redemption fees in qualified retirement plans for those funds that decide to adopt such fees.

We believe that it is not in the best interests of active savers in qualified retirement plans that short term redemption fees be imposed on transactions over which they either have no control (i.e., plan sponsor fund change) or which are executed because of an appropriate response to life changes (i.e., shifting investment allocation as the participate ages). These are not market-timing activities.

Redemption fees should apply only to participant directed exchanges where the fund was purchased through a previous participant directed exchange, as opposed to shares that were purchased through salary deferral or plan sponsor contributions.

Redemption fees should not apply to loans, distributions or withdrawals, plan sponsor fund replacements, rebalancing of participant accounts directed by the plan sponsor, or any other transaction over which an individual participant has no control.

The lack of uniformity between fund companies, individual funds within fund companies, as to fee amount, holding period, affected transactions, and possible waivers, make recommending funds and communicating their policies confusing and frustrating for plan sponsors and participants. It is likely that the work necessary to track the various fees, time periods, and affected transactions will result in higher costs to plan sponsors, eroding the returns for active savers in qualified retirement plans.

We appreciate Commission's efforts to stop market timing and excessive trading abuses in order to protect mutual fund investors. Thank you for allowing us to express our views.